There is a growing concern from iGaming stakeholders in Finland that the proposed player protection recommendations would see the majority of gambling taking place on the black market.
The Gambling Harm Risk and Harm Assessment Group in the Ministry of Social Affairs and Health has been told by Wildz Group that the proposed recommendations would weaken player protections.
In addition, the proposals have been called “too restrictive” by SkillOnNet, who argued that they will negatively impact channelisation rates and increase gambling harm.
The supplier lamented the lack of attention that it believes is currently being paid to eradicating the black market.
Player protection proposals have been pitched by Finland’s new gambling act to prevent and reduce gambling harm in the commercially licensed market.
Measures include land-based slots having more stringent loss limits than online slots, loss limits – triggered at daily, monthly and annual limits – being centralised by government decree, as well as a centralised location where players can review their gambling expenditure, with data reported to government officials.
The assessment group’s consultation period is still open until 24 February, but two iGaming stakeholders have already voiced their concerns.
Comparison with Germany
Wildz has argued that the measures presented could see the majority of the country’s gambling taking place away from licensed operators, referencing how the iGaming market in Germany has developed.
“The recommendations of the evaluation group should explicitly take into account the channelling capacity of the gambling system in further preparation,” Wildz said in its response.
“In connection with the licensing system implemented in Germany, several studies have estimated that only approximately 20–30% of gambling (measured by gambling margin) is channelled into the regulated offer in a situation where the restriction level is set too low in relation to player behaviour.
“If the restrictions presented in the recommendations were applied in Finland without an assessment of the channelling effects, it is justified to assume a similar outcome. In this case, the result would be that the majority of gambling would take place outside the licensing system, player protection would be weakened, the scope of official supervision would be narrowed and the central objective of the Gambling Act would not be achieved.”
Channelisation
SkillOnNet has stated that the proposals are “too restrictive and would lead to the reform falling far short” of achieving a high channelisation rate, as well as preventing and reducing problem gambling.
Regarding channelisation, the company said that money transfer limits for Finnish players upon registering have been set because there are other things within the law that “reduce the degree of channelling”.
“For example, during the project, means were removed from the law to prevent the provision of games outside the operating license, and general affiliate marketing is also prohibited in the gambling industry.”
SkillOnNet noted that temporarily freezing accounts that hit deposit limits would negatively impact channelisation as “every time a customer is directed to look for a new gaming venue, the risk of finding a site operating outside the system increases”.
“We cannot avoid this within the framework of the law, as the gaming offering outside the licence and their digital marketing will not be controlled. Therefore, deposit and gaming limits cannot be separated from the larger context and tightened so radically when the Gambling Act is already complete in other respects.
“Strict deposit limits, together with the new Gambling Act, would increasingly drive players outside the system. There is also concrete evidence from Germany, for example, of the detrimental impact of strict gaming and money transfer limits on the channelling rate.”
Problem gambling
As for preventing and reducing problem gambling, SkillOnNet argued that the proposed restrictions will cause people to create multiple gaming accounts. This would increase the risk of problem gambling, as well as “drive people at risk of gambling problems to gamble outside the licensing system”, where they are not given protection.
“If the goals are failed in terms of the degree of channelisation, they are also failed in terms of gambling harms,” the company stated.
“One of the reasons that led to the legal reform was that Veikkaus’ market share of all gambling was now around 50%, and Veikkaus could therefore no longer claim to take care of Finnish players. Nothing will change for the better if the new licensing system achieves a similar degree of channelisation.”
SkillOnNet is asking for more attention to be paid to how black market operators can be eliminated, as well as directing resources to licensed operators’ duty of care.
“In our opinion, the assessment group on gambling harms should pay the most attention to how the most harmful of all, i.e. gambling outside the licensing system, could be eradicated.
“In licensed gaming, on the other hand, resources should be directed to ensuring that licensees adhere to their own duty of care and report on it actively, that the restrictions set by the players themselves are adhered to and that the national gambling ban register functions flawlessly.”